Organophosphate and Carbamate Plant Protection Pesticides

Transcription

1 Jan Submission on EPA Proposal Application Organophosphate and Carbamate Plant Protection Pesticides I make this submission as a home gardener, supporting the general thrust of the proposal but opposing the recommendations relevant to Home Garden Use clause in the application. Clause Organo-phosphate & Carbamate insecticides pose a number of risks to human health and the environment. In many cases these risks can be mitigated through the use of personal protective equipment or implementation of buffer zones and re- entry intervals, but such measures are unlikely to be appropriately applied in a home environment. The EPA considers that home users do not have knowledge or awareness to manage these high hazard products. The home garden is also a place where the most sensitive individuals (e.g. very young children) are most likely to be present. Information on poisoning incidents involving OPC s indicates that a large proportion of accidental exposures relate to exposures at home, and many of these appear to involve children. Recommendation To mitigate this risk the EPA proposes the application of an approved handler control on all of the substances for which such approvals are to be retained. This will ensure that only trained agrichemical handlers will apply OPC s in home gardens and they should inform the home owner as to the risks of the substances. Home garden OPC products - Target containing the OP pirimiphos -methyl Yates Shield, Gild, McGregor s Rose Spray, - containing the OP acephate Kiwicare Carbaryl containing the carbamate - carbaryl Kiwicare Maldison containing the OP- maldison McGregor s General Insect containing the OP - diazinon Kiwicare Lawn Prills, Yates Soil Insect Killer, - containing the OP diazinon as a granule. Kiwicare Spectrum containing the OP chlorpyrifos

2 Pyrifos containing chlorpyrifos as a granule (Not currently on the review schedule but recently launched in the Home Garden Market) The current regulations (which will be retained or even enhanced for OPC s) state that all the above require an approved handler. There is currently an exemption for home garden use on the grounds that the quantities being sprayed are small, involving minutes not hours or days of spraying, applied by low pressure hand sprayers, and the concentrates are much lower strength. Diazinon granules are applied from a shaker pack. (Target & Diazinon granules currently have a qualified approved handler requirement which is likely to become full) The proposed EPA changes will remove the current exemption for the home garden products above and would in future require an approved handler to be present whenever the above products are applied. In addition retailers will be required to have an Approved Handler and will only be able to sell these products to an approved handler. Considerations 1) We are pleased that the EPA have recommended retaining the currently approved OPC s in use in the home garden market, by taking note of the following -. a) Diazinon granules (Kiwicare Lawn Prills & Yates Soil Insect Killer) are still the only products that will control grass grub and porina caterpillar in lawns, and carrot rust fly in carrots. b) Carbaryl and Maldison are the only two home garden insecticides approved for use on the following -- VEGETABLES Asparagus; Aubergine; Beans; Carrots; Celery; Cucurbits; Garlic; Leeks; Lettuces; Peas FRUITS Blueberries; Brambles; Citrus; Currants; Feijoa; Gooseberry; Grape; Passionfruit; Pip Fruit; Stone Fruit; Strawberries. There is no effective approved alternative to maldison & carbaryl for home gardener use on these crops c) Because of their low toxicity and short withholding period, carbaryl and maldison can be used closer to harvest than alternatives. d) Target has approval for most but not all crops and is considerably more effective on a wider range of insect pests than maldison or carbaryl, but has a longer withholding period. e) Although soft chemical options (vegetable oil fatty acids, BTK) can be used close to harvest, they are more expensive and less effective than synthetic insecticides. f) Carbaryl and Maldison remain by far the lowest cost insecticides for home gardeners. g) There is concern that if OPC s are withdrawn from home garden use, there is increased risk of resistance occurring with the limited alternatives, and inability to vary treatments. Are there alternatives? a) Mavrik (tau-fluvalinate) Confidor (imidacloprid) and Success Naturalyte (spinosad) could in theory replace the OPC sprays between them, but this would require a very significant expansion of label claims, which is unlikely to happen. Mavrik is a good option to push for expansion because it is currently approved for about half the vegetables and some fruits, it is broad spectrum, controlling the main sucking and chewing insects, has low toxicity and is safe to bees.

3 c) Soft chemicals such as vegetable oil fatty acids, & BTK, have a place but are less effective, require at least twice as many applications and are more expensive. d) Organic products such as Pyrethrum; Neem Oil, and Derris, which have until now escaped the laws are in fact of greater concern than OPC s. Pyrethrum contains the synergist piperonyl butoxide which has been shown to be toxic, and was the most frequently recorded insecticide residue in the latest (2009) Total Food Study Residue Analysis undertaken. Pyrethrum is mostly used by organic gardeners so much for organic food having no pesticide residues. Neem oil contains the known carcinogen aflatoxin, and is not approved for use on food crops but is currently promoted for this purpose by the suppliers. (refined formulations have some food crop approval). Derris now has proven links to Parkinsons disease. 2 The proposed approved handler requirement (clause 10.18) will in practice have a combination of the following effects - a) dramatically reduce sales and use of OPC s in home gardens. b) increase the off label use of alternative insecticides some of which are likely to be more toxic. c) sales of OPC s will continue contrary to new regulations d) cause an impossible log jam of gardeners seeking to become an approved handler 3 Justification for the EPA proposal has some question marks. Clause quotes poisoning incidents in the home and specifically children as a reason for the approved handler control proposal. Analysis of the poisoning enquiries to the National Poisons Centre for the last full year shows the following Total Children Therapeutic agents 33% 16.6% Household agents 25.3% 14.6% Agriculture agents -total 5.5% 1.2% - Insecticides 1.1% 0.2% Estimated OPC insecticides (46% of total based on home garden sales) 0.50% 0.09% OPC insecticides are a very minor percentage of enquiries and these come from access to improperly stored products rather than use. I suggest that if EPA is so concerned about OPC s requiring an approved handler for use, why is it that we allow home owners to use therapeutic drugs, household cleaners etc which are more hazardous and which account for nearly 600x more enquiries to the poisons centre. Therapeutic drugs and household cleaners are over 1500 times more likely to poison children than an OPC insecticide.

4 Hospitalisations of suspected OPC Poisoning Information Source Massey University / EPA Ingestion / Exposure Record Very Vague Commercial use - vague Home use - vague Records too vague Intentional Ingestion 10 Total Hair shampoo Pet wash Garden Accidental Ingestion Home Use Exposure Commercial Spill Exposure 3 Commercial Use Exposure 2 Not an OPC (Ethanol from Glyphosate) 1 Points to note 1. Records are too vague in to draw actionable conclusions in 48% of cases If we ignore the vague records and analyse the remainder 2. Intentional Ingestion makes up 32% 3. Accidental Ingestion makes up 29% 4. Exposure in use makes up 35% (Hair & Pet 13% Garden 6% Commercial 16%) 5. 39% were caused by personal hygiene / pet treatments containing OPC s 6. 10% were caused by home garden products 7. 16% were caused by commercial products 8. In 75% of cases the causal product was not known or not recorded. There is a high probability that many of the Vague category above may not have been caused by an OPC. It is also probable that many of the recorded OPC poisonings were in fact due to other pesticides or substances, as there is no record, and the symptoms are not necessarily typical OPC symptoms.

5 From the writers experience of 25 years dealing with front line technical complaints and suspected poisonings, it is common for blame to be attached to organo-phosphates, 245-T, or glyphosate, simply because these are products in common use and always in the news in a negative manner without good reason. The writer is aware of many records of poisonings, pesticide / herbicide damage that are false. The Massey study shows that most poisonings were accidental or intentional ingestion. The accidental ingestions were mainly hair shampoo containing maldison for nit control, and pet shampoo containing Asuntol. It is highly likely that home owners believe these products to be safe as they are used on hair and pets. This leads to a false sense of security. Garden pesticides on the other hand are perceived as very toxic and are always receiving negative press, which leads to home owners being more careful and security conscious. App clause 5.1 As further evidence I can say that for eight years at Yates, I was responsible for technical aspects of pesticides and registration. During this time I received many enquiries about health aspects, associated risk, and possible effects of pesticides. 80% of users referred to all agrichemicals as organophosphates or 245T. Hence I would not place too much credence on the vague records of the poisons centre. I am also aware first hand of wrong diagnosis of pesticide poisoning by Doctors. App clause 5.2 Exposure The risk from exposure to OPC s being used in the home garden is extremely small. The vague information from The Poisons Centre does not specify. I know from my eight years at Yates in the 1980 s, that 90% + of human incidents involved children who had accessed a package improperly stored. With most of today s pesticides being liquid formulations in containers with childproof caps, this would have minimised this problem. App clause 5.3 In 1982 I introduced regular cholinesterase testing of all staff that worked in the pesticide mixing / packing factory at Yates. At that time approximately 15% of product packed was OPC. After 2 years there was not one single case of lowered cholinesterase in the 12 staff involved. Therefore I suggest there is little evidence on these grounds to justify the EPA proposal. App Clause 6.2 Uses acephate carbaryl Home Garden Use. The preferred insecticide for roses, and ornamentals because of its broad spectrum, (most sucking & chewing insects), systemic action, excellent efficacy, low cost, and relatively low toxicity. It is the insecticide of choice in several major brands of rose spray. If acephate is restricted, tau-fluvalinate will partially fill the gap or a mixture of imidacloprid & spinosad will be required. This will greatly increase the cost. For many years has been the insecticide of choice for vegetables (in particular tomatoes and brassicas) and fruits (in particular pip and berry fruit) for caterpillar control because of its efficacy, 1 day withholding period, low cost and relatively low toxicity. Tau-fluvalinate is a good alternative and has replaced carbaryl to some extent. The limiting factor for tau-fluvalinate is that it is only approved for use on some vegetables and fruits. There are over 25 fruit and vegetable crops that only carbaryl and maldison are

6 diazinon maldison pirimiphos Chlorpyrifos approved for. In addition the withholding period for some crops is weeks rather than days. Diazinon is available to home gardeners as a liquid concentrate and a granule. The liquid concentrate is used very little because acephate is preferred being equally effective and lower toxicity. (Diazinon is labelled Poison ) The granule formulation is the only control available for grass grub in lawns and carrot rust fly, and hence is one of the largest selling insecticides for the home garden. For many years has been the insecticide of choice as a general purpose low cost insecticide. In recent years however, acephate, pirimiphos, and more latterly tau-fluvalinate have become more popular because of superior efficacy, no smell and relatively low toxicity. Tau-fluvalinate is a good alternative and has replaced maldison to some extent. The limiting factor for tau-fluvalinate is that it is only approved for use on some vegetables and fruits. There are over 25 fruit and vegetable crops that only carbaryl and maldison are approved for. In addition the withholding period for some crops is weeks rather than days. Yates Target (pirimiphos + permethrin) was very popular from 1980 to 2000 because it had reasonably broad registration covering most vegetables. It was more effective than a maldison carbaryl mix and easier to use. Its use in recent years has dropped significantly because of the high price. Tau-fluvalinate has become the replacement. This insecticide is present in one insecticide fungicide combination product which is a small seller. It is not essential for home gardeners. It is avoided because of the higher level of toxicity than other products. As a matter of interest, acephate and maldison remain two of the largest selling home garden insecticides in USA. An anomaly exists in the proposal relating to carbaryl. It is proposed to add a 12 hour Re- entry interval (R12) but there is a nil withholding period for tomatoes. This means that tomatoes are safe enough to pick immediately following spraying, but one cannot enter the garden to do so for 12 hours. (cynical journalists will take EPA to task with this one) Alternatives are listed in the table above. Alternatives for home gardeners are limited, because in effect they are limited primarily to imidacloprid, tau-fluvalinate, and spinosad. Most insecticides in home gardens are applied to roses, fruits, and vegetables. Imidacloprid is a good insecticide for sucking insects on ornamentals, but only has registration for Onions, lettuces and brassicas, (the last two with a 35 & 70 day withholding period respectively) which makes it of little use on edibles. Tau-fluvalinate is the best alternative to OPC s with very broad spectrum insect control but registration on fruit and vegetables is still very narrow. It is probably currently the most used insecticide off label. (to avoid using OPC) Spinosad is a good alternative but is limited a) it only controls chewing insects, b) registration for edibles is still very narrow.

7 Other options - Home gardeners practice good cultural husbandry to minimise pests and diseases and we concur with the summary as set out in the application proposal App Clause 7.1 Adverse Effects on Society. The public do have a perceived fear of pesticides. Local authority sprayers and commercial growers applying pesticides certainly generate most fear. This fear is mostly caused by negative inaccurate articles / items in magazines, newspapers, TV and radio. A long list of examples is available if required. App Clause 7.2 Social Benefit. Gardening has been NZ s most popular pastime / hobby for many years. Gardeners state the following reasons benefits of gardening a) satisfaction b) relaxation of the mind c) creating a feel good factor in the home environment d) saving on edibles e) the freshness of edibles f) adding value to the property, g) doing our bit for the environment. All of these things contribute to wellbeing. Although good cultural practice can minimise pests and diseases, successful gardening is extremely difficult without pesticides. Over recent years there has been an increase in new younger gardeners who don t have the skills and knowledge. When these gardeners don t receive the right advice and secure control of pests, they lose interest in the garden. The garden market has declined a little in recent years (47 garden centres with a combined turnover of 38m have closed in the last 10 years) Total garden market at retail stands at approx. $500m Recommendations a) I support the Application proposal to retain acephate as it is a popular efficient broad spectrum insecticide that provides an alternative should resistance occur in new insecticides. b) I support the Application proposal to retain carbaryl and maldison because they provide the only approved insecticide option for some 25 vegetables and fruits. It is our desire that suppliers will work to broaden registration of tau-fluvalinate or other alternatives for fruit and vegetables which are the main use for insecticides. c) I support the Application proposal to retain diazinon but want clarification on method restriction (R7). The proposed restriction to prohibit hand held application is understandable for broad dispersion to large areas. However we recommend that home garden shaker packs for distribution be approved. d) I oppose the proposed control on home garden OPC insecticides as set out in clause This control is unnecessary, will create huge angst with gardeners most of whom will not be bothered to become certified, will use more alternatives off label at possibly greater risk or may well procure product from approved handler friends contravening regulations. e) The vast majority of garden retailers do not have an Approved Handlers certificate. There will be extra work for retailers endeavouring to police this. Who is responsible for policing the user and how? The analysis of National Poisons Centre report shows that 58% of poison enquiries are for therapeutic or household agents and only 0.1% for OPC insecticides. For children there are 31% of enquiries for therapeutic and household agents and only 0.02% for OPC. Based on

8 this information this regulation requiring home garden users to hold an Approved Handlers certificate is not required. Anecdotally far more children are poisoned from gaining access to an improperly stored product (therapeutic, household or agricultural remedy) than being exposed to its use. The Massey hospitalisation study indicates most cases are accidental or intentional ingestion rather than exposure in use or after use. Furthermore this study indicates that hospitalisation from exposure to home garden insecticides is minimal with only one case in the entire period of the study. I Recommend Consideration of Alternative Controls We acknowledge that it would be desirable for home gardeners to have a greater knowledge of pesticides. Some garden centres do an excellent job of this with web sites, brochures in store, talks in store and one on one service. On the other hand there are some (especially mass merchandisers) where information or advice would not be readily available. 1. I recommend that in place of requiring the home gardener to be an approved handler that garden retailers be required to have a Growsafe Certified Person (which includes an approved handler ) available to talk to customers at the point of sale. This would be in line with the current situation where a pharmacist can sell certain prescription medicines without a doctor s prescription but only after confirming diagnosis of problem, and suitability of the medicine sought. The appropriate advice and cautions are given at the time of sale. The Growsafe qualification I refer to is one written especially for home gardeners in 2000 by Reg Lewthwaite (Unitec) and the writer. To the writer s knowledge this course has never been implemented, but should be, and now is the time. 2. I recommend a return to previous labelling regulations where the word Poison is in bold capitals at the top of the front label panel. This will do more to - a) deter use of OPC s. b) ensure gardeners take extra care if they do choose to use them. 3. I recommend that home garden packs / use, remain exempt from the controls that apply to commercial applications buffer zones; personal protection; re-entry periods; notification; and approved handler I wish to appear and speak in support of this submission before the Committee. I have been asked to appear on behalf of other submitters, (Kings Plant Barn, Palmers Garden World, Garden Independents Network, California Garden Centre) and advise that only one appearance is required to cover them all. This submission is made as a home gardener and on behalf of my many home garden friends. William H (Bill) Brett 1 Blomfield Pl

9 Motueka Ph